J-0200000-10 KWSPCC.pdf

SPILL PREVENTION, CONTROL,

AND COUNTERMEASURE (SPCC) PLAN

NAVAL AIR STATION KEY WEST

KEY WEST, FLORIDA

Under Contract to:

Naval Facilities Engineering Command Southeast Region Headquarters

PO Box 30, Bldg. 135 North, Ajax Street NAS Jacksonville, FL 32212

Navy Contract

N69450-13-D-0017-72

August 2018

Prepared by:

This page intentionally left blank.

AUGUST 2018 iii

Contents Acronyms and Abbreviations ............................................................................................................. vii

Plan Administration ......................................................................................................................... 1-1

1.1 Executive Summary ............................................................................................................ 1-1

1.2 Cross-Reference with SPCC Provisions............................................................................... 1-2

1.3 Management Approval ...................................................................................................... 1-5

1.4 Professional Engineer Certification .................................................................................... 1-7

1.5 Designated Person ............................................................................................................. 1-9

1.6 Location of SPCC Plan ......................................................................................................... 1-9

1.7 Amendments of SPCC Plans ............................................................................................... 1-9

1.7.1 Five Year Plan Reviews ........................................................................................... 1-9

1.7.2 Facility Change Amendments............................................................................... 1-10

1.7.3 Spill Reports & EPA Directed Amendments ......................................................... 1-11

General Facility Information ............................................................................................................. 2-1

2.1 Facility Description ............................................................................................................. 2-1

2.2 Oil Storage Containers ....................................................................................................... 2-4

2.2.1 High-Risk Oil Storage Facilities ............................................................................... 2-6

2.2.2 Ancillary Aboveground Storage Tanks ................................................................. 2-23

2.2.3 Mobile Refueler Trucks and Portable Containers ................................................ 2-23

2.2.4 Used Cooking Oil Containers ................................................................................ 2-24

2.2.5 Drum Storage Areas ............................................................................................. 2-24

2.2.6 Facility Piping ....................................................................................................... 2-24

2.2.7 Underground Storage Tanks ................................................................................ 2-24

2.2.8 Oil-Filled Operational Equipment ........................................................................ 2-25

2.2.9 Oil/Water Separators ........................................................................................... 2-26

2.2.10 Other Containers (Out of Service, Permanently Closed, or Temporary Contractor Containers)......................................................................................... 2-27

Conformance and Environmental Equivalence .................................................................................. 3-1

3.1 Conformance with Requirements ...................................................................................... 3-1

3.2 Environmental Equivalence ............................................................................................... 3-1

3.3 Facilities or Equipment Not Yet Fully Operational ............................................................. 3-1

3.3.1 Boca Chica Refueler Truck Parking ......................................................................... 3-1

3.3.2 Removal of Out of Service Tanks ........................................................................... 3-1

3.3.3 Replace A-1006 and A-1025 Facilities .................................................................... 3-2

Predicted Spills as Result of Equipment Failure ................................................................................. 4-1

4.1 Discharge Notification and Response Procedures ............................................................. 4-1

4.2 Predicted Spill Scenarios .................................................................................................... 4-1

4.2.1 High-Risk Oil Storage Facilities ............................................................................... 4-2

4.2.2 Other Ancillary Tanks ............................................................................................. 4-6

4.2.3 Mobile Refueler Trucks .......................................................................................... 4-7

4.2.4 Drum Storage Areas ............................................................................................... 4-8

SPCC PLAN – NAS KEY WEST

iv AUGUST 2018

4.2.5 Oil-Filled Operational Equipment .......................................................................... 4-8

4.2.6 Other Ancillary Piping ............................................................................................ 4-9

4.3 Discharge or Drainage Controls ....................................................................................... 4-10

4.4 Disposal of Recovered Materials ..................................................................................... 4-11

Secondary Containment ................................................................................................................... 5-1

5.1 Requirements ..................................................................................................................... 5-1

5.2 Secondary Containment for Stationary Bulk Storage Tanks .............................................. 5-2

5.2.1 Freeboard for Precipitation .................................................................................... 5-2

5.2.2 Sufficiently Impervious ........................................................................................... 5-2

5.2.3 Field Constructed Tanks ......................................................................................... 5-3

5.2.4 Shop-Fabricated Ancillary Tanks ............................................................................ 5-3

5.3 Secondary Containment for Mobile and Portable Containers .......................................... 5-7

5.3.1 Portable Generators and Tanks ............................................................................. 5-7

5.3.2 Mobile Refueler Trucks .......................................................................................... 5-7

5.3.3 Drum Storage Areas and Used Cooking Oil Containers ......................................... 5-9

5.4 Secondary Containment for Loading and Unloading Racks ............................................. 5-10

5.4.1 Industry Standard Consideration ......................................................................... 5-10

5.5 Secondary Containment for Fuel Transfer Areas ............................................................. 5-10

5.6 Secondary Containment for Piping .................................................................................. 5-12

5.7 Oil-Filled Operational Equipment .................................................................................... 5-13

5.8 Impracticability of Secondary Containment .................................................................... 5-14

Inspections and Testing .................................................................................................................... 6-1

6.1 Inspection Schedule and Recordkeeping ........................................................................... 6-1

6.2 Stationary Bulk Storage Tank Inspections .......................................................................... 6-3

6.2.1 Field Constructed Tanks ......................................................................................... 6-3

6.2.2 Shop-Fabricated Tanks ........................................................................................... 6-4

6.2.3 Industry Standard Considerations.......................................................................... 6-8

6.3 Mobile and Portable Container Inspections ...................................................................... 6-9

6.4 Liquid Level Sensing Device Inspections .......................................................................... 6-10

6.4.1 Field Constructed Tanks ....................................................................................... 6-10

6.4.2 Shop-Fabricated Tanks ......................................................................................... 6-10

6.4.3 Mobile Refueler Trucks ........................................................................................ 6-10

6.4.4 Industry Standard Considerations........................................................................ 6-11

6.5 Aboveground Piping Inspections ..................................................................................... 6-11

6.6 Containment Dike Inspections ......................................................................................... 6-12

6.7 Underground Storage Tank Inspections .......................................................................... 6-13

6.8 Underground Piping Inspections ...................................................................................... 6-13

6.9 Oil Water Separator Inspections ...................................................................................... 6-14

6.10 OFOE Inspections ............................................................................................................. 6-14

Oil-Handling Personnel Training ....................................................................................................... 7-1

7.1 Initial SPCC Training ........................................................................................................... 7-1

7.2 Annual Discharge Prevention Briefings .............................................................................. 7-2

7.3 State UST Operator Training .............................................................................................. 7-2

CONTENTS

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Security ............................................................................................................................................ 8-1

8.1 Site Access and Fencing ..................................................................................................... 8-1

8.2 Master Flow and Drain Valves ........................................................................................... 8-1

8.3 Starter Controls .................................................................................................................. 8-1

8.4 Pipeline Loading and Unloading Connections.................................................................... 8-2

8.5 Lighting ............................................................................................................................... 8-2

Procedures for Fuel Transfers ........................................................................................................... 9-1

9.1 Loading/Unloading of Military Refueler Trucks ................................................................. 9-1

9.1.1 General Transfer Procedures ................................................................................. 9-2

9.2 Commercial Fuel Delivery Trucks to Bulk Fuel Tanks ......................................................... 9-4

9.3 Refueler Trucks to Ancillary Containers ............................................................................. 9-4

9.4 Hand Pour into Containers (Used Cooking Oil / Used Engine Oils) ................................... 9-5

9.5 Vacuum Truck from Containers (Used Cooking Oil / Used Engine Oils) ............................ 9-6

9.6 Over the Water Fueling to Large Marine Vessels .............................................................. 9-7

9.7 Dispenser Hose to Small Boats and Motor Vehicles .......................................................... 9-7

9.8 Refueler Trucks to and from Aircraft ................................................................................. 9-8

Brittle Fracture Evaluation.............................................................................................................. 10-1

Conformance with State and Local Applicable Requirements .......................................................... 11-1

11.1 State Regulatory Standards .............................................................................................. 11-1

11.1.1 Petroleum Contact Water .................................................................................... 11-1

11.1.2 Underground Storage Tanks ................................................................................ 11-1

11.1.3 Aboveground Storage Tanks ................................................................................ 11-5

11.2 Other Relevant Standards .............................................................................................. 11-16

Other SPCC Requirements .............................................................................................................. 12-1

12.1 Container Construction .................................................................................................... 12-1

12.2 Corrosion Protection for Buried, Partially Buried and Bunkered Storage Tanks ............. 12-1

12.3 Corrosion Protection for Buried Piping ............................................................................ 12-2

12.4 Heating Coils..................................................................................................................... 12-2

12.5 Overfill Prevention ........................................................................................................... 12-2

12.6 Effluent Treatment Facility .............................................................................................. 12-4

12.7 Terminal Connections ...................................................................................................... 12-4

12.8 Pipe Supports ................................................................................................................... 12-4

12.9 Vehicle Warning ............................................................................................................... 12-5

12.10 Facility Drainage: Design and Equipment ........................................................................ 12-5 vi AUGUST 2018

Appendices

A Tank Data Sheets AB Equipment Photos B Facility Diagrams C Inspection Forms and Checklists D Record of Initial Training and Annual Discharge Prevention Briefings E Record of SPCC Plan Five Year Reviews and Amendments F Assumptions and Calculations

Tables

1-1 Regulatory Cross-Reference Matrix 2-1 Summary of Oil Storage Containers & Capacities 2-2 Oil Water Separators 2-3 Container Inventory and Summary of Conditions 2-4 Oil-Filled Operational Equipment 3-1 List of Tank Deficiencies 5-1 Secondary Containment Volumes of Single-Walled Tanks 5-2 Secondary Containment Volumes Mobile or Portable Containers 5-3 Secondary Containment Volumes Drum Storage Areas / Used Cooking Oil Containers 5-4 Secondary Containment Volumes for High-Risk Loading / Unloading Areas 6-1 Inspection Schedule 6-2 Tank Category and Inspection Requirements 6-3 STI SP001 Periodic Testing Requirements 11-1 Relevant Military & Industrial Standards

Figures

2-1 Location Map 2-2 Boca Chica Tank Farm 2-3 Boca Chica Truck Fill Stand & Refueler Parking Area 2-4 Boca Chica NEX Station 2-5 Boca Chica Power Plant 2-6 Fleming Key Army Special Forces 2-7 Sigsbee Park NEX Station 2-8 Sigsbee Park Marina 2-9 Truman Annex – Facility 289 Generators

AUGUST 2018 vii

Acronyms and Abbreviations A/C Air Conditioning AIMD Aircraft Intermediate Maintenance Depot ANSI American National Standards Institute API American Petroleum Institute ASME American Society of Mechanical Engineers AST Aboveground Storage Tank ATG Automatic Tank Gauge

BCTF Boca Chica Tank Farm BOQ Bachelor Officer’s Quarters BUMED Bureau of Medicine

CDO Command Duty Officer CFR Code of Federal Regulations CHRIMP Consolidated Hazardous Material Reutilization and Inventory Management Program CO Commanding Officer CP Cathodic Protection CPOA Chief Petty Officer’s Association

DASR Digital Airport Surveillance Radar DLA-E Defense Logistics Agency – Energy DMS Data Monitor Systems DoD Department of Defense DOT Department of Transportation DSA Drum Storage Area

EPA Environmental Protection Agency

FAA Federal Aviation Administration FAC Florida Administrative Code FDEP Florida Department of Environmental Protection FKAA Florida Keys Aqueduct Authority FRAMP Fleet Replacement Aviation Maintenance Program FRC Fleet Readiness Center FRP Facility Response Plan ft Feet gal/ft3 Gallons Per Cubic Feet gph Gallons Per Hour gpm Gallons per Minute GRI Guidance for Regional Inspectors (USEPA) GSE Ground Support Equipment viii AUGUST 2018

HAZWOPER Hazardous Waste Operations and Emergency Response HW Hazardous Waste

JIATFS Joint Inter-Agency Task Force South JP-5 Jet Propulsion Fuel

KWPC Key West Pipeline Company

LOX Liquid Oxygen

MIL-STD Military Standard MSL Mean Sea Level MWR Morale, Welfare, and Recreation

N/A Not Applicable NASKW Naval Air Station Key West NATOPS Naval Air Training and Operating Procedures Standardization NAVAIR Naval Air Systems Command NAVFAC-SE Naval Facilities Engineering Command – Southeast NAVSEA Naval Sea Systems Command NBHC Naval Branch Health Clinic NEX Navy Exchange NFPA National Fire Protection Association NOAA National Oceanic and Atmospheric Administration NRL Naval Research Laboratory

OFOE Oil-Filled Operational Equipment OLS Online Service OPNAV M Navy Operations Manual OPS Operations OPV Overfill Prevention Valve OS Out of Service OSWER Office of Solid Waste and Emergency Response OWS Oil Water Separator

PAR Precision Approach Radar PCW Petroleum Contact Water PE Professional Engineer PEI Petroleum Equipment Institute PIV Post Indicator Valve POL Petroleum, Oil, and Lubricant psi Pounds Per Square Inch PWD Public Works Department

RAPCON Radar Approach Control

CONTENTS

AUGUST 2018 ix

RATCC Radar Air Traffic Control Center RDC Regional Dispatch Center RPM Revolutions Per Minute RV Recreational Vehicle

SAR Synthetic Aperture Radar SOP Standard Operating Procedure SPCC Spill Prevention, Control, and Countermeasure STI Steel Tank Institute

TACAN Tactical Air Navigation System TCTS Tactical Combat Training System

UCO Used Cooking Oil UFC Unified Facilities Criteria UL Underwriters Laboratories ULSD Ultra Low Sulfur Diesel U.S. United States UST Underground Storage Tank

VAQ Visiting Airman’s Quarters Vol Volume

WWTP Wastewater Treatment Plant x AUGUST 2018

AUGUST 2018 1-1

SECTION 1

Plan Administration

1.1 Executive Summary

Title 40 in Code of Federal Regulations (CFR) section 112.1(d)(2)(ii), requires a Spill Prevention Control and Countermeasure (SPCC) plan to be written, if the facility has greater than 1,320 gallons of total aboveground fuel/oil storage capacity. This includes all fixed position tanks, integral generator tanks, mobile refueler trucks, cooking oil tanks, portable containers, drums, and Oil-Filled Operational Equipment (OFOE), such as transformers and hydraulic elevator tanks, with at least a 55-gallon capacity.

Naval Air Station Key West (NASKW) exceeds the 40 CFR 112 threshold capacity as detailed in Table 2-3, and so is required to maintain a SPCC plan.

The purpose of this SPCC plan is to identify all tanks, containments, procedures, methods and equipment used at NASKW, to prevent the discharge of oil into the environment. This plan is applicable to all facilities and organizations located at NASKW that store or handle, new or used, fuel or oil products, in aboveground tanks and equipment. NASKW previously maintained an SPCC Plan in accordance with these regulations. This revised plan is a technical update to address facility oil storage changes during the past five years and to maintain compliance with 40 CFR 112 regulations.

Naval Facilities Engineering Command – Southeast (NAVFAC-SE) Region provided oversight and technical assistance with the preparation of this document through NAVFAC-SE Contract N69450-13-D-0017, Task Order 0072. MSE Group, LLC (formerly 3E Consultants, Inc.) and CH2M performed evaluations at NASKW in November 2016 and collected available information and data for inclusion in the SPCC Plan. This included the visual evaluation of all aboveground storage tanks (AST), visible portions of underground storage tanks (UST), and connected fuel piping. In addition to container inspections, oil water separators (OWS), refueler truck parking and transfer locations, drum storage areas (DSA), other mobile/portable oil tanks and inspection procedures were evaluated for effectiveness and industry best management practices.

NASKW has an inspection program for storage containers and transfer areas; and if needed, deficiencies are noted and programmed for correction. NASKW also has an effective program for improving regulated oil containers through tank replacements and equipment upgrades to meet industry standards. NASKW maintains a Facility Response Plan (FRP) to address discharges of oil per 40 CFR 112.20, and discharge of hazardous substances in accordance with Navy Operations Manual (OPNAV M-) 5090.1D, Chapter 39.

The Environmental Division is pro-active with respect to training and ensures NASKW meets federal, state, and local regulations. Appropriate NASKW personnel have been identified and trained for spill prevention and response, and written procedures guide personnel performing inspections and monitoring of regulated activities. Because NASKW is dynamic by nature, it is important to continue the practices of training and monthly inspections for spill prevention as equipment degrades, and personnel rotate through the facility.

NASKW is presently in substantial conformance with SPCC requirements. However, there are a few existing conditions that should be addressed in order to ensure full compliance with 40 CFR 112. Refer to Table 3-1 for a Tank Summary of Conditions, noting the regulatory deficiencies and best engineering practice recommendations identified in this SPCC Plan. The NASKW Public Works Department (PWD), 1-2 AUGUST 2018

Environmental Division Office (Building A-626) maintains a current database of SPCC inspection reports and corrective action status.

The United States (U.S.) Environmental Protection Agency (EPA) definition of “Facility” is subject to interpretation, but it usually includes all buildings, structures, or properties, which are contiguously located, and owned or operated by the same organization (such as a Navy base). Boca Chica Key, Fleming Key, Naval Branch Health Clinic (NBHC), Saddlebunch Key, Sigsbee Park, Truman Annex, and Trumbo Point are non-contiguous Navy-owned properties, which are managed by NASKW. Generally, the PWD at NASKW is responsible for environmental compliance, asset management, training, and record-keeping for these locations. Although separate, the sites are included in this single Plan because they are centrally-managed, and for program continuity, administrative, and cost benefits. Tenant commands and contractors are responsible for oil storage and/or transfer operations at various buildings or complexes on NASKW.

The contractor owned and operated Key West Pipeline Company (KWPC), who supplies jet propulsion fuel (JP-5) by pipeline from their facility at Trumbo Point to the Boca Chica Tank Farm, maintains a separate SPCC plan and FRP for their bulk fuel storage tanks and pipelines, so the KWPC facilities are not included in the SPCC plan for NASKW.

1.2 Cross-Reference with SPCC Provisions

“112.7: If you do not follow the sequence specified in this section for the Plan, you must prepare an equivalent Plan acceptable to the Regional Administrator that meets all of the applicable requirements listed in this part, and you must supplement it with a section cross-referencing the location of requirements listed in this part and the equivalent requirements in the other prevention plan.”

TABLE 1-1

Regulatory Cross-Reference Matrix

Regulation Citation

(40 CFR 112)

Regulatory Requirement Description

SPCC Plan Section

112.3(d) Professional Engineer (PE) Certification Section 1.4

112.3(e)(1) Location of SPCC Plan Section 1.6

112.4 Amendments by Regional Administrator Section 1.8.2

112.5(a) Amendments Section 1.8, Appendix E

112.5(b) SPCC Plan Review Section 1.7

112.7 Management Approval Section 1.3

112.7 Facilities or Equipment Not Yet Fully Operational Section 3.3

112.7(a)(1) Conformance with Requirements Section 3.1

112.7(a)(2) Environmental Equivalence Section 3.2

112.7(a)(3) Facility Description Section 2.1, Appendix B

SECTION 1 – PLAN ADMINISTRATION

AUGUST 2018 1-3

(40 CFR 112)

Regulatory Requirement Description

SPCC Plan Section

112.7(a)(3)(i) Oil Storage Containers Section 2.2

112.7(a)(3)(ii) Discharge Prevention Measures Section 9, Appendix A

112.7(a)(3)(iii) Discharge or Drainage Controls Section 4.3

112.7(a)(3)(iv) Discharge Discovery Countermeasures Section 4.1

112.7(a)(3)(v) Disposal of Recovered Materials Section 4.4, FRP

112.7(a)(3)(vi) Contact List Section 4.1, FRP

112.7(a)(4) Discharge Notification Section 4.1, FRP

112.7(a)(5) Discharge Response Procedures Section 4.1, FRP

112.7(b) Predicted Spill Scenarios Section 4.2, Appendix F

112.7(c) Secondary Containment Requirements Section 5.1

112.7(d) Impracticability of Secondary Containment Section 5.7

112.7(e) Inspections Schedule and Recordkeeping Section 6.1

112.7(f)(1) Initial SPCC Training Section 7.1, 7.2

112.7(f)(2) Designated Person Section 1.5

112.7(f)(3) Discharge Prevention Briefings Section 7.2

112.7(g) Security Section 8

112.7(h)(1-3) Transfer Procedures for Loading and Unloading Racks Section 9.1

112.7(i) Brittle Fracture Evaluation Section 10

112.7(j) Conformance with Applicable State and Local Requirements Section 11

112.7(k) Oil-Filled Operational Equipment (OFOE) Section 5.6

112.8(b)(1-2) Containment Dike Inspections Section 6.6

112.8(b)(3-4) Facility Drainage: Design and Equipment Section 12.10

112.8(b)(5) Facility Drainage: Pump Transfer Section 12.11

112.8(c)(1) Container Construction Section 12.1

112.8(c)(2) Secondary Containment for Stationary Bulk Storage Tanks Section 5.2

112.8(c)(3)(i-iv) Containment Dike Inspections Section 6.6

1-4 AUGUST 2018

(40 CFR 112)

Regulatory Requirement Description

SPCC Plan Section

112.8(c)(4 - 5) Corrosion Protection for Buried, Partially Buried, and Bunkered Storage Tanks

Section 12.2

112.8(c)(6) Stationary Bulk Storage Tank Inspections Section 6.2, 6.3

Mobile and Portable Container Inspections Section 6.3

112.8(c)(7) Heating Coils Section 12.4

112.8(c)(8)(i-v) Liquid Level Sensing Device, Overfill Prevention Section 6.4, 12.5

112.8(c)(9) Effluent Treatment Facilities Section 12.6

112.8(c)(10) Correct Visible Discharges Section 4.3

112.8(c)(11) Secondary Containment for Mobile or Portable Containers Section 5.3

112.8(d)(1) Corrosion Protection for Buried Piping Section 12.3

112.8(d)(2) Terminal Connections Section 12.7

112.8(d)(3) Pipe Supports Section 12.8

112.8(d)(4) Aboveground Piping Inspections Section 6.5

112.8(d)(5) Vehicle Warning Section 12.9

AUGUST 2018 1-5

1.3 Management Approval

“112.7: The Plan must have the full approval of management at a level of authority to commit the necessary resources to fully implement the Plan.”

This SPCC Plan has the full approval of management at NASKW, at a level of authority to commit the necessary resources for full implementation of the Plan. Management will use personnel, equipment, and materials necessary to prevent and control spills, and to implement SPCC requirements set forth in this Plan. By virtue of my office, I have authority to approve this document on behalf of the facility, and to commit resources to implement the corrective actions and improvements needed, to comply with applicable federal and state laws.

The implementation of and compliance with this SPCC Plan are subject to the provisions of the Anti- Deficiency Act, as amended, 31 United States Code section 1341 et seq, and requisite regulations which control funding of operations and activities. Nothing in this plan is intended to make or authorize an expenditure or obligation, exceeding an amount or purpose available in a U.S. Government appropriation or fund, for an expenditure or obligation in violation of the Anti-Deficiency Act. Further, this plan is not intended to involve the U.S. Government in a contract or obligation for payment or any other expense, before an appropriation is adopted, unless otherwise authorized by law.

Signature Date Signed

BAKER.BOBBY.JOHN.1144409

Digitally signed by

BAKER.BOBBY.JOHN.1144409902

Date: 2018.09.14 13:38:33 -04'00' 9/14/18

1-6 AUGUST 2018

AUGUST 2018 1-9

1.5 Designated Person

“112.7(f)(2): Designate a person at each applicable facility who is accountable for discharge prevention and who reports to facility management.”

The PWD, Environmental Director, located in Building A-626, telephone (305) 293-2911 is the primary Designated Person, described in 40 CFR 112.7(f)(2), who reports to NASKW management and is accountable for discharge prevention.

The first backup designated person is the SPCC/Tank Manager, Jeffrey Dale, telephone (305) 293-2881.

The second backup person to call, in case of emergency, is the 24-hour Command Duty Officer (CDO), telephone (305) 797-4428.

1.6 Location of SPCC Plan

“112.3(e)(1): Maintain a complete copy of the Plan at the facility if the facility is normally attended at least four hours per day or at the nearest field office if the facility is not so attended, and Have the Plan available to the Regional Administrator for on-site review during normal working hours.”

In accordance with 40 CFR 112.3(e)(1), a complete copy of this Plan is maintained and available for review during normal working hours, at the PWD – Environmental Division, at Building A-626.

Naval Air Station Key West P.O. Box 9007 Key West, Florida 33040-9007

1.7 Amendments of SPCC Plans

1.7.1 Five Year Plan Reviews

“112.5(b): Notwithstanding compliance with paragraph (a) of this section, complete a review and evaluation of the SPCC Plan at least once every five years from the date your facility becomes subject to this part; or, if your facility was in operation on or before August 16, 2002, five years from the date your last review was required under this part. As a result of this review and evaluation, you must amend your SPCC Plan within six months of the review to include more effective prevention and control technology if the technology has been field-proven at the time of the review and will significantly reduce the likelihood of a discharge as described in §112.1(b) from the facility. You must implement any amendment as soon as possible, but not later than six months following preparation of any amendment. You must document your completion of the review and evaluation, and must sign a statement as to whether you will amend the Plan, either at the beginning or end of the Plan or in a log or an appendix to the Plan. The following words will suffice, “I have completed review and evaluation of the SPCC Plan for (name of facility) on (date), and will (will not) amend the Plan as a result.”

The Designated Person identified in Section 1.5 is responsible for initiating and coordinating the SPCC Plan reviews. The Facility Owner/Operator, Designated SPCC person, NAVFAC-SE region, or authorized contractor firm, must complete a review of the SPCC plan and on-site evaluation of the facility oil storage tanks at least once every five (5) years, or when significant changes in the Facility occur. The completed review and evaluation must be followed by a signed statement as to whether the Plan will be amended. The record of the SPCC Plan Five-Year Reviews and Amendments is contained in Appendix E.

40 CFR 112.3(d) requires that SPCC plan 5-year updates and technical amendments must be reviewed and certified by a licensed Professional Engineer (PE).

1-10 AUGUST 2018

The SPCC Plan must be amended within six (6) months of the review and evaluation to include all identified facility changes, and more effective field-proven prevention and control technology, that will significantly reduce the likelihood of a discharge from regulated oil tanks and oil transfers. The site must implement any SPCC plan update or amendment as soon as possible, but not later than six (6) months following the preparation and PE certification of any amendment.

1.7.2 Facility Change Amendments

“112.5(a): Amend the SPCC Plan for your facility in accordance with the general requirements in §112.7, and with any specific section of this part applicable to your facility, when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge as described in §112.1(b). Examples of changes that may require amendment of the Plan include, but are not limited to: commissioning or decommissioning containers; replacement, reconstruction, or movement of containers; reconstruction, replacement, or installation of piping systems; construction or demolition that might alter secondary containment structures; changes of product or service; or revision of standard operation or maintenance procedures at a facility. An amendment made under this section must be prepared within six months, and implemented as soon as possible, but not later than six months following preparation of the amendment.”

The SPCC plan must be amended when there is a change in the Facility design, construction, operation, or maintenance that materially or significantly affects the Facility’s potential for an oil discharge, in quantities that may be harmful, into or upon navigable or surface waters, or adjoining shorelines, or into a drainage system that may connect to open waters, or an oil discharge that may seriously affect natural resources. Examples of changes include, but are not limited to the following:

• Commissioning or decommissioning containers.

• Replacement, reconstruction, or movement of containers.

• Reconstruction, replacement, or installation of piping systems.

• Construction or demolition that might alter secondary containment structures.

• Changes of product or service.

• Revision of standard operation, inspection, or maintenance procedures.

A plan technical amendment to include any of these changes must be prepared within six (6) months after the change occurs and must be implemented as soon as possible, but not later than six (6) months following preparation of the amendment. 40 CFR 112.3(d) requires that SPCC plan 5-year updates and technical amendments must be reviewed and certified by a licensed PE.

Non-technical amendments can be made by the Designated SPCC person, which are documented in the appropriate plan section. Non-technical amendments can include administrative updates, such as changing facility or person names and telephone numbers, correcting data errors, and noting that ancillary tanks were removed or taken out of service (OS).

The record of SPCC Plan Five-Year Reviews and Amendments is contained in Appendix E.

AUGUST 2018 1-11

1.7.3 Spill Reports & EPA Directed Amendments

“112.4(a): Notwithstanding compliance with §112.3, whenever your facility has discharged more than 1,000 U.S. gallons of oil in a single discharge as described in §112.1(b), or discharged more than 42 U.S. gallons of oil in each of two discharges as described in §112.1(b), occurring within any twelve-month period, submit the following information to the Regional Administrator within 60 days from the time the facility becomes subject to this section:

• Name of the facility.

• Name of the owner or operator of the facility.

• Location of the facility.

• Date of initial facility operation.

• Maximum storage or handling capacity of the facility and current normal daily throughput.

• Description of the facility, including maps, flow diagrams, and topographical maps.

• A complete copy of the SPCC Plan with any amendments.

• The cause of such spill, including a failure analysis of the system or subsystem in which the failure occurred.

• The corrective actions and/or countermeasures taken, including an adequate description of equipment repairs and/or replacements.

• Additional preventive measures taken or contemplated to minimize the possibility of reoccurrence.

• Such other information as the EPA Regional Administrator may require.”

If any spill were to occur at the facility that meets the criteria of 40 CFR 112.4(a), which is listed above, then a written spill report must be submitted to the EPA Regional Administrator within 60 days.

Following receipt of the facility spill report, the EPA may decide to require an amendment to the SPCC Plan, and the facility will be notified by certified mail. EPA will specify the terms of such a plan amendment.

Within 30 days from receipt of the notice, the facility may submit written information, views, and arguments on the proposed amendment. After considering all material presented, EPA will either notify NASKW that an amendment is required or will rescind the notice.

Any EPA proposed amendment becomes a part of the SPCC Plan 30 days after such notice, unless NASKW appeals. The amendment should be implemented as soon as possible, but not later than six months after the amendment becomes a part of the SPCC Plan.

NASKW did not discharge more than 1,000 U.S. gallons of oil in a single discharge as described in §112.1(b), or discharge more than 42 U.S. gallons of oil in each of two discharges as described in §112.1(b), occurring within any twelve-month period. As such, NASKW was not required to submit their SPCC Plan with any amendments to the EPA for review. The NASKW list of reportable spills is maintained at the PWD Environmental Office.

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AUGUST 2018 2-1

SECTION 2

General Facility Information Facility Owner/Operator: Commanding Officer

Facility Name: Naval Air Station Key West

Address: Commanding Officer Naval Air Station Key West P.O. Box 9007 Key West, Florida 33040-9007

Telephone: (305) 293-2866

2.1 Facility Description

“112.7(a)(3): Describe in your Plan the physical layout of the facility and include a facility diagram, which must mark the location and contents of each container. The facility diagram must include completely buried tanks that are otherwise exempted from the requirements of this part under §112.1(d)(4). The facility diagram must also include all transfer stations and connecting pipes.”

NASKW is comprised of approximately 5,800 acres of land distributed over several properties in the Florida Keys, in Monroe County, Florida. NASKW is located approximately 156 miles southwest of Miami and 90 air miles north of Cuba. This SPCC plan addresses oil storage at the following non-contiguous properties which are managed by NASKW: Boca Chica Key, Trumbo Point, Truman Annex, Fleming Key, Sigsbee Park, Saddlebunch Key, and NBHC. See Facility diagrams in Appendix B.

The mission of NASKW is to “Support operational and readiness requirements for the Department of Defense (DoD), Department of Homeland Security, National Guard, Federal Agencies and Allied Forces.”

The surrounding annexes support NASKW and its mission. Storage of oil products is a vital component for the successful execution of the mission requirement at NASKW and the surrounding annexes. Oil storage container types addressed in this plan are ASTs, USTs, DSAs, and mobile/portable storage. In addition, OFOE is present on NASKW and includes transformers and hydraulic oil reservoirs for elevator lifts.

Boca Chica Key

The Boca Chica Key is an island approximately three miles east of the city of Key West. This facility contains the largest quantity of oil storage at NASKW. Boca Chica is where aircraft are maintained, and flight operations are performed. Boca Chica contains four field-erected JP-5 bulk fuel tanks, and a backup loading/unloading area, at the Defense Logistics Agency – Energy (DLA-E) contractor-operated Tank Farm. Across the airfield runways, there is a separate DLA-E contractor-operated Truck Fill Stand, and mobile refueler parking area. Also, there is a Navy Exchange (NEX) mini-mart and vehicle fueling station; Navy Gateway Inn; Morale, Welfare, and Recreation (MWR) Marina (with no boat fueling); and several other shop-fabricated tanks, drum/mobile storage, used cooking oil (UCO), and OFOE.

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Trumbo Point

The Trumbo Point site is located on the northwest end of the city of Key West, adjacent to the U.S. Coast Guard station. This area includes a Naval Air Systems Command (NAVAIR) pier (where ship fueling is performed), the Navy Gateway Inn (main office), and an entrance to Fleming Key. This area contains several ASTs, one DSA (on Pier D-1), and OFOE (transformers).

Trumbo Point is where KWPC receives fuel shipments by barge and stores bulk fuel in three field-erected tanks. An underground and underwater pipeline originates here and transfers fuel to NASKW at the Boca Chica Tank Farm. These tanks and pipeline are owned and operated by KWPC and are not included in this Plan.

Truman Annex

Truman Annex is located on the southwest corner of the city of Key West. This area includes the Joint Inter-Agency Task Force South (JIATFS) facility, Mole Pier (where ship fueling is performed), Navy Port Operations, Navy Gateway Inn, and other facilities that contain ASTs, DSAs, UCO, and OFOE (transformers).

Fleming Key

The oil storage at Fleming Key is exclusively for the Army Special Forces facility, which is located approximately two miles north of the city of Key West. This area contains an Army dock (where small boat fueling is performed) and several Army-operated ASTs, drum/mobile storage, and OFOE.

Sigsbee Park

The Sigsbee Park area is an island 0.5 miles north of the city of Key West. This facility has three USTs at the NEX vehicle fueling station, a NEX commissary and store, MWR Marina (where small boat fueling is performed), Navy Lodge, family housing, and several ASTs, UCO, and OFOE (transformers).

Saddlebunch Key

Saddlebunch Key is approximately 7 miles east of Boca Chica and 12 miles east of the city of Key West.

This is a former communications facility, which is currently used for special forces operational training.

This facility has one generator day tank and OFOE (transformers).

Naval Branch Health Clinic

NBHC is located on the northeast corner of the city of Key West. This is a Bureau of Medicine (BUMED) operated facility, which includes an emergency generator AST and day tank system, and OFOE (hydraulic elevator lifts).

Refer to the Vicinity Map, Figure 2-1, for a depiction of NASKW location and each site that makes up the facility, and to Appendix B for a facility diagram.

SECTION 2 – GENERAL FACILITY INFORMATION

AUGUST 2018 2-3

FIGURE 2-1

Location Map

Topography in and around the NASKW area is typically flat and low with ground elevations ranging from 0 to 15 feet above mean sea level (MSL). The average elevation in the area is approximately four to five feet above MSL and is below the 100-year flood elevation of 8 feet above MSL. Typically, the islands are bordered by low intertidal flats which gradually slope to deeper water. The highest point of the runway system at Boca Chica Field is 6 feet above MSL.

Geology of the NASKW area consists of shallow marl (lime rich mud) over limestone with limestone rock outcrops at many locations. Many areas surrounding annexes have been filled and graded. In addition, some of the areas are land mass developed from the disposal of dredge material (Sigsbee Park and parts of Trumbo Point Annex).

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Approximately 50 percent of the NASKW area is drained by storm sewers. Drainage occurs via overland flow and gravity feed to storm sewer systems that route runoff to nearby tidal waters. The average annual rainfall at NASKW is 40 inches with more than half of the annual rainfall occurring in the five months from June to October. The NASKW area has periodically been subject to hurricane activity. Most of the hurricanes that have affected NASKW have approached from the south and east and have brought high winds and tidal flooding to the area.

Storm water drainage at NASKW, including Boca Chica, Fleming Key, Trumbo Point, Truman Annex, and Sigsbee Park, is comprised of 41 separate drainage basins. There are 32 basins with direct discharges, either through drainage pipes or concentrated ditch flows. There are nine (9) drainage basins that either sheet flow to low points with no apparent outfall, or sheet flow off-site with no concentrated outfall.

2.2 Oil Storage Containers

“112.7(3)(i): You must also address in your Plan the type of oil in each fixed container and its storage capacity. For mobile or portable containers, either provide the type of oil and storage capacity for each container or provide an estimate of the potential number of mobile or portable containers, the types of oil, and anticipated storage capacities;

(capacities of 55 gallons or greater)”

NASKW stores a variety of petroleum, oil, and lubricants (POLs) for use in ground vehicles, aircraft, marine vessels, as well as fuel for back-up emergency electricity generation. These POLs are stored in a variety of ASTs and USTs throughout NASKW (reference Appendix A and Appendix B for site-specific figures for USTs, ASTs, and DSAs). In addition, ASTs containing used POLs and animal/vegetable cooking oils are situated at locations throughout NASKW. Various types of OFOE (electrical transformers and hydraulic oil reservoir tanks) are found on NASKW. In addition, 55-gallon drums containing engine oils (new and used) are located throughout NASKW. Other oil storage containers or transport areas such as mobile equipment, loading areas, OWSs, and facility piping are found at NASKW and are also discussed in this Plan, where appropriate.

The total oil storage capacity is summarized in Table 2-1. Information on OWS units at NASKW is found in Table 2-2. Information pertaining to ASTs, and mobile/portable equipment that meet the criteria specified in 40 CFR 112 can be found in Table 2-3. Information pertaining to OFOE can be found in Table 2-4. USTs are counted separately as discussed in Section 2.2.7.

TABLE 2-1

Summary of Oil Storage Containers & Capacities

Container Type Quantity Total Oil Storage Capacity (gallons)

Additional Details

Bulk Field-erected ASTs 4 895,002 See Appendix A

Shop-Fabricated AST 74 133,564 See Appendix A

Out of Service AST 8 8,070 See Appendix A

Mobile/Portable Storage 8 48,941 See Appendix AB

Drum Storage 16 3,685 See Appendix AB

OFOE (Hydraulic Oil Containers) 6 573 See Appendix AB

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TABLE 2-1

Summary of Oil Storage Containers & Capacities

Container Type Quantity Total Oil Storage Capacity (gallons)

Additional Details

OFOE (Pad-mounted Transformers) 102 21,647 See Appendix AB

UCO 3 625 See Appendix AB

Total Aboveground Oil Storage Capacity 1,112,107

USTs 3 22,000 See Appendix A

Total Oil Storage Capacity (with USTs) 1,134,107

Each of the items listed in Table 2-1 is addressed in this Plan, in the following order:

1. High-Risk Oil Storage Facilities

• Boca Chica Tank Farm - Facility A-930

• Boca Chica Truck Fill Stand & Refueler Truck Parking Area – Facility A-935 & A-4196

• Boca Chica NEX Station – Facility A-322

• Boca Chica Power Plant – Facility A-419 F&G

• Fleming Key Army Special Forces – Facility F-02 and F-03

• Sigsbee Park NEX Station – Facility V-4043

• Sigsbee Park Marina – Facility V – 4186

• Truman Annex – Facility 289

2. Ancillary Aboveground Storage Tanks

3. Mobile Refueler Trucks and Portable Containers

4. Used Cooking Oil Containers

5. Drum Storage Areas

6. Facility Piping

7. Underground Storage Tanks

8. Oil-Filled Operational Equipment

• Elevator Hydraulic Oil Tanks

• Electrical Transformers

9. Oil Water Separators

10. Other Containers (Out of Service, Permanently Closed, or Temporary Contractor Containers)

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2.2.1 High-Risk Oil Storage Facilities

High-risk oil storage sites at NASKW were established based upon review of both the volume of oil stored at each location, and the frequency of transfer operations completed at that facility. The sites are listed below.

2.2.1.1 Boca Chica Tank Farm – Facility A-930

The NASKW Boca Chica Tank Farm (BCTF) is located at the south end of Midway Avenue, between Runway 8-26 and Runway 4-22. This facility is a government-owned, contractor-operated facility. Data Monitor Systems (DMS) operates the bulk fuel storage and transfer services at NASKW, under a contract with DLA-E.

There are four field-erected ASTs that store JP-5 in the following bulk quantities:

• A-938 – 194,009 gallons

• A-944 – 207,129 gallons

• A-945 – 226,318 gallons

• A-958 – 267,546 gallons

There are four shop-fabricated ASTs that store products in the following quantities:

• A-924-R1 – 12,000 gallons, Off-Spec JP-5

• A-925-R1 – 12,000 gallons, Used Oil

• A-933-A – 1,000 gallons, JP-5 and Water

• A-4240-G – 220 gallons, Diesel

The bulk storage ASTs are equipped with high-level alarms and manual shut-off valves. There are no automatic high-level control valves or overfill prevention valves (OPV) installed on fuel receipt inlet pipeline. The bulk storage AST bottoms are provided with cathodic protection using an impressed-current system. Detailed information on the tanks at the BCTF is included in Appendix A.

KWPC is a contractor-owned and -operated bulk fuel storage facility, which provides JP-5 aircraft fuel to the bulk storage ASTs at the BCTF, through a KWPC-owned, 4-inch diameter, carbon steel, underground and underwater pipeline, installed in…